1

Date: 26 May 2021

Version: V4.3

Name of originator/ author: Emily Dwyer, Senior Corporate Governance Manager

Complaints report

Annual and Quarter Four 2020/21 NHS Brighton and Hove CCG

NHS East Sussex CCG

NHS West Sussex CCG

2

Item Content Page number

1.0 Executive summary 3

2.0 Complaints activity 4

3.0 Themes 7

4.0 Serious incidents 8

5.0 Outcome of formal complaints 8

6.0 Lessons learnt 10

7.0 Informal enquiries and concerns 11

8.0 MP enquiries and corporate correspondence 11

9.0 Compliments 12

10.0 Equality and diversity monitoring 13

11.0 Parliamentary and Health Service Ombudsman (PHSO) and Local Government Ombudsman

13

12.0 Horizon scanning: 2021/22 14

Appendix A: Summary of quarter four activity 16

Appendix B: Lessons learnt quarter four 17

Appendix C: Complaints themes 2020/21 22

3

1.0 Executive summary

The purpose of this report is to provide the Executive Management Team with an overview

of the complaints received by the Sussex CCGs during the period 2020/21. The report

details the trends and themes from feedback the CCGs have received during this period.

Contacts from the public within this report include formal complaints, (including complaints

received from MPs), signposting and informal contacts, plaudits, corporate

correspondence, claims, and any complaints escalated to the Parliamentary and Health

Service Ombudsman (PHSO).

This report presents:

• The volume, subjects and themes of complaints and enquiries received • Areas of recommended change in practice • Assurance that there are effective systems and mechanisms to ensure that

lessons are learnt and shared throughout the CCGs

The Sussex CCGs recognise that patients have a range of experiences when using local healthcare services. It is essential that the organisations provide service users with a mechanism to tell us about both positive and negative experiences. Where possible, the organisations take immediate action to put things right for service users. Where this is not possible, the organisations have a robust complaints process. The data collated through complaints, patient concerns, dissatisfaction, compliments, and corporate correspondence play a significant role in improving the quality of care and service experience of patients and their families, which continues to be a priority for the CCGs. During 2020/21 there were 965 contacts made to the Complaints team across the three CCGs. The total number of formal complaints received by the CCGs during 2020/21 was 288. It is difficult to provide a comparison with those received in previous years as each organisation reported their data differently. The volume of patient concerns and enquiries was 413 which also provide a valuable insight into patient experience of local health services. In managing complaints the CCGs work in accordance with the Complaints policy which

follows the requirements of the NHS (Complaints) Regulations 2009, the PHSO Principles

of Good Complaint Handling (2009) and the NHS England / Improvement (NHSE / I)

Complaints Handling for CCGs (2013).

As with all teams within the NHS, this has been a challenging year for the Complaints

team, with members of the team seconded to support the COVID-19 Incident Management

Team and the vaccine enquiries team. This was further exacerbated by NHSE/I and the

PHSO pausing their complaints processes during the first lockdown which led to increased

enquiries from MPs and patients alike, particularly in relation to primary care services.

During 2020/21 the CCGs’ complaints management process was audited by TIAA (the

internal audit provider) and an opinion of ‘reasonable assurance’ was provided. The

auditors noted that “where complaints are regarding CCG commissioned services, good

practices were noted from the sample of cases reviewed.”

4

TIAA made recommendations for the service, predominantly relating to the management

of provider complaints, clearly identifying on the database how these are processed and

making amendments to the Complaints policy to include the management of CCG-led

provider complaints. These recommendations have since been fully implemented, the

Complaints policy has been refreshed, significant improvements have been made to the

database, and in future the database will be able to provide more detail around identifying

trends and any necessary service improvements going forward.

1.1 Definitions

Formal Complaint - When a person makes a statement that something is unsatisfactory or unacceptable. A formal investigation and response is required.

Informal enquiry / concern - Where the concern raised is managed informally, with the agreement of all parties and usually within three working days. A person may also be asking for information, advice or making a constructive suggestion. An enquiry may escalate into a formal complaint should the enquirer remain dissatisfied or require deeper investigation. A proportion of enquiries require an investigation and a written response from the CCGs.

2.0 Complaints activity

During 2020/21 there were 288 formal complaints received, of which 198 were managed by the CCGs. Complainants can specifically ask the CCGs to ‘lead’ on a complaint if the complaint relates to a service commissioned by the CCGs or if there are multiple parties involved. On occasion it may also be deemed more appropriate for a provider to lead on a complaint. In such cases the CCGs’ Complaints team will request a copy of the response with the complainant’s consent. It should be noted that MP enquiries are not included in these figures. These have previously been handled by another team. From June 2021 these will be handled by the Complaints team which will allow for better monitoring of trends and comprehensive reporting.

5

Chart 1: Complaints received per CCG, 2020/21

* Please see section 2.3 for a description of ‘complaint types’.

NHS West Sussex CCG continues to receive the highest number of complaints (50.6% of

the total) but it is worth noting that there is a larger population in West Sussex and the

percentage of complaints is proportionate to the population.

2.1 Acknowledgement of complaints

The NHS (Complaints) Regulations 2009 state that complaints should be formally

acknowledged within three working days.

During 2020/21 95% of complaints were acknowledged within three working days. The

remaining 5% were acknowledged outside of the three working day timescale due to

complexity, delays in cases being identified as formal complaints and cases moving from

informal enquiries to formal complaints. Every complaint was acknowledged within five

working days.

The Complaints team has now been directed to acknowledge all correspondence,

irrespective of whether the CCG investigates, or if the correspondence is directed

elsewhere, within three working days.

20

1

5

16

45

1

6

38

59

9

20

32

0

5

10

15

20

25

30

35

40

45

50

55

60

65

Complex Complaint Serious Complaint CCG Led ProviderComplaint

MP/Political Complaint

Number of complaints received per CCG, 2020/21

Brighton And Hove CCG East Sussex CCG West Sussex CCG

6

Table 1: Acknowledgement time by CCG, 2021/21

Total Complaints received

% Acknowledged within 3 working days

% Exceeded 3 working days

NHS Brighton and Hove CCG 51 94% 6%

NHS East Sussex CCG 93 97% 3%

NHS West Sussex CCG 144 94% 6%

Overall total 288 95% 5%

2.2 Responding to complaints There is no definitive timeframe set out in the NHS (Complaints) Regulations 2009 for responding to complaints. It is considered best practice that complainants are updated on a regular basis, particularly when the previously-agreed timeframe is expected to be exceeded. During 2020/21 the CCGs’ Complaints policy set out the following response times: Table 2: CCG complaint categories and target response times

During 2020/21 50% of complaints fell into the complex category and had a 30 working day response timescale. If a complaint is particularly complex or involving more than one department or organisation, the regulations allow for a longer response time (up to a maximum of six months). This is discussed and agreed with the complainant on receipt of the complaint or in the course of the investigation when the complexity becomes apparent. Serious complaints or complaints involving multiple providers are managed by the South, Central and West Commissioning Support Unit (SCW CSU) on behalf of the CCGs with the consent of the complainant. SCW CSU and CCG Complaints teams meet monthly to ensure shared learning and ongoing continuing development of quality assured responses. As referenced above, when a complaint is received in relation to a service commissioned by the CCGs, the complainant has the choice as to whether the CCGs lead on the

Seriousness of complaint

Target timescale for response

Complex (C) 30 working days

Serious (S) 40 working days

7

complaint or it is sent directly to the provider organisation to lead on it. The latter is generally more expeditious but in all cases the CCGs ask to receive a copy of the response in order to assist in monitoring services. The following table sets out the average number of days, and median number of days it has taken the organisations to respond to complaints. Included in this brief analysis are:

Complex complaints that should be responded to within 30 days

MP complaints that should be responded to within 30 days Table 3: Response times during 2020/21

Average number of days to respond to a complex complaint

Median number of days to respond to a complex complaint

NHS Brighton and Hove CCG 42 42

NHS East Sussex CCG 48 41

NHS West Sussex CCG 49 44

Sussex NHS Commissioners 48 43

Complaints relating to providers that the CCG have been asked to lead on should be

responded to within 40 days; on average the organisation has taken an average of 74

days to respond to these complaints, with a median response time of 72 days.

Although there is no definitive timeframe set out in the NHS (Complaints) Regulations

2009 for responding to complaints, regulatory authorities would rather complainants are

provided with full responses and kept informed as to delays. The delays that are incurred

are not due to the lack of a thorough investigation, but are due to delays in reviews of

investigations by Heads of Departments, and delays in approvals due to executive

capacity.

The Complaints team and Director of Governance and Corporate Services are working on

a complaints improvement plan to encourage engagement with the team across the

organisation, a key elements of which will include the development of dashboard reporting

of the complaints position across the directorates. It is hoped that such reporting will lead

to improved response times.

3.0 Themes

A complaint can be regarding more than one service and contain a number of themes.

During 2020/21 the highest number of complaints or concerns were in relation to GP

practices, Continuing Healthcare, Planned Care and Mental Health services. This is

reflective of the current situation regarding the pandemic response and the consequent

delays and lack of face-to-face appointments patients are experiencing.

8

Within the past twelve months complainants have identified a wide range of concerns,

which include:

GP practice concerns, relating to level of care, and delays in referral to both secondary care and specialist services

GP practice and Continuing Healthcare concerns, relating specifically to unprofessional staff attitude towards patients

Continuing Healthcare concerns specifically relating to the outcomes of assessments

Failure to carry out appropriate public consultation prior to relocation, merger or closure of GP practices

Lack of coordination between primary and secondary care

Delays to appointments and waits for surgery

Concerns relating to mental health provision and CAMHS

Prescribing decisions

Other – concerns relating to multi-agency complaints, often with multiple complex issues

Please see appendix C for an exhaustive list of complaint themes during 2020/21.

4.0 Serious Incidents (SI)

Of the complaints received during 2020/21, there were none identified as potentially

involving a Serious Incident (SI). Should the Complaints team recognise any potential SIs

they are also reported to the Quality team or, if it relates to a provider, the provider is

informed and told to report it as an SI.

5.0 Outcome of Formal Complaints

Under the Local Authority Social Services and National Health Service Complaints (England) Regulations 2009 the CCGs have a statutory duty to record and report:

The number of complaints received

The number that were well founded

The number referred to the PHSO

The subject matter of complaints

Matters of importance arising from the complaints or handling thereof

Action taken, or being taken, to improve services as a result of complaints received

It is important to note that, whilst not all complaints may be well-founded, the CCGs consider that all complaints and concerns provide insight into patients’ experiences and an opportunity for learning. In line with the PHSO’s approach to categorising the outcome of complaints, the CCGs record complaints as either ‘upheld’, ‘partially upheld’ or ‘not upheld’. The PHSO’s definitions of these are as follows:

9

Upheld

This could mean we found that:

The organisations made mistakes or provided a poor service that amounted to maladministration or service failure, and

This has had a negative impact on an individual that has not yet been put right.

Partially upheld

We might partly uphold a complaint if:

We found that the organisations got some things wrong, but not all the issues that were complained about, or

The mistakes made did not have a negative effect on anyone.

Not upheld

This could mean we found:

The organisations acted correctly in the first place, or

The organisations made mistakes but have already taken action to put things right for the person or people affected.

Table 4 below illustrates the outcomes attributed to complaints received during 2020/21

(this does not include reopened cases or cases carried forward from predecessor CCGs):

10

Table 4: Complaint outcomes 2020/21

Complaint outcome

NHS Brighton and

Hove CCG

NHS East Sussex

CCG

NHS West Sussex

CCG

Total 2020/21

Upheld 3 5 9 17

Partially upheld 7 10 27 44

Not upheld 8 24 20 52

Regraded to informal / PALS 1 0 5 6

Case not pursued by complainant 10 16 23 49

Handed to Claims team

0 1 0 1

Provider handled complaints

16 18 28 62

Carried forward to Q1 2021/22

6 15 36 57

Total 51 89 148 288

As per the table above, of the 119 known outcomes of complaints closed in 2020/21 ,

51% (61) were upheld or partially upheld and 44% (52) were not upheld; the remaining 5%

(6) were regraded to informal / Patient Advice and Liaison Service (PALS) due to swift

action. Of the total complaints (288) received 22% were forwarded to a provider to

respond with no outcome notified to the CCGs and 17% were closed due to no further

contact from the complainant or consent not provided. 57 complaints have been carried

forward from 2020/21 into 2021/22.

With regards to the ‘provider handled complaints’ the Complaints team follows up with

complainants to ask that they share the provider complaint response with us. Owing to

information governance restrictions, complainants need to give consent to providers to

share a response with the CCGs, so the CCG team cannot ask the provider directly for

complaints responses. When the Complaints team receives a response the outcome is

recorded on the system. This approach is consistent with other CCGs’ practice and with

SCW CSU.

6.0 Lessons learnt from complaints – turning intelligence into

improvement

Robert Francis QC highlighted the importance of complaints in enabling NHS

organisations to develop and sustain a culture in which the patient is at the heart of service

design and delivery. “Complaints, their source, their handling and their outcome provide an

insight into the effectiveness of an organisation’s ability to uphold both the fundamental

standards and the culture of caring. They are a source of information that has hitherto

been undervalued as a source of accountability and a basis for improvement.”

11

The Sussex CCGs welcome feedback, whether adverse or complimentary, as it enables

learning from the experiences of patients, carers and service users, and allows measures

to be put in place to improve services for everyone.

All outcomes of investigations are reviewed by the relevant Head of Service together with

the Executive Managing Director for the relevant CCG. There are clear expectations that

actions will be undertaken when complaints are well- or partially well-founded. The

Complaints team follows up on the progress of these actions in order to ensure that

service improvements are made and to hold responsible managers to account.

Please see appendix B for further detail regarding lessons learnt during quarter four. This

appendix explains that there were nine complaints that lead to direct changes being

implemented across the CCGs. The largest number related to changes to procedures to

facilitate swifter responses or to join up care provision.

7.0 Informal Enquiries and Concerns

The Complaints team also deals with informal enquiries and signposting, formerly known

as PALS enquiries.

During this reporting period, the CCGs handled a total of 413 informal enquiries in addition

to the formal complaints and corporate correspondence.

Table 5: Number of informal enquiries by CCG

Name of CCG

Informal Complaint (Numbers)

NHS Brighton and Hove CCG 74

NHS East Sussex CCG 155

NHS West Sussex CCG 184

Total 413

Whilst the CCGs do not provide a formal PALS service, the Complaints team endeavours

to resolve all informal enquiries quickly for the patient and to limit any further escalation to

becoming a formal complaint. However, on occasion, some of the informal enquiries the

CCGs receive are time consuming, complex and require the involvement of multiple

organisations and departments. If enquiries cannot be resolved in a satisfactory way, the

patient can escalate their concern as a formal complaint.

8.0 MP enquiries and corporate correspondence

There continues to be a notable increase in the number of MP enquiries received by the

CCGs since the start of the Covid-19 pandemic. During quarter four these were managed

12

and logged by the Chief Executive’s Office in accordance with a newly introduced

Standard Operating Procedure.

Table 6 below sets out the volume of corporate correspondence and claims managed by

the Complaints team. It includes some of the MP enquiries managed by the Chief

Executive’s Office in 2020/21.

Table 6: Volume of MP enquiries, claims and corporate correspondence by CCG

Type of correspondence

NHS Brighton and

Hove CCG

NHS East Sussex

CCG

NHS West Sussex

CCG

Total 2020/21

MP enquiry 19 35 44 98

Corporate letter 4 7 14 25

Claim 1 2 2 5

Total 24 43 61 128

Of the five claims, four related to clinical care at provider organisations and the other one

related to a CHC personal health budget. They were redirected to the CCGs’ Head of

Legal Services.

The main themes of MP correspondence include:

Access to services and / or delayed appointments / admissions. These

included ear irrigation services, acute trusts admissions, CAMHS, and

mental health

GP practice issues

Covid-19 related issues including test results, provision of long-Covid clinics

and access to Covid-19 vaccine

Access to NHS dentist

Management of DNAR during COVID-19

Medication issues

All of the cases were managed to the satisfaction of the MP involved.

9.0 Compliments

As commissioners the CCGs would not expect to receive a high volume of compliments

compared with NHS provider organisations. That said 72 plaudits have been recorded in

2020/21. In keeping with previous years the majority of compliments relate to CHC, as this

service has the highest number of direct contacts with members of the public. However,

the Complaints team also note there have been compliments related to CCG functions and

to other providers that have often been incorporated within a complaint letter. The

Complaints team ensures that these are acknowledged and that they are shared with the

relevant teams to recognise and celebrate best practice.

13

10.0 Equality and diversity monitoring

The Complaints team is in the process of reviewing the online survey form used to monitor

equality and diversity information. The link to the survey is provided to all complainants as

part of the complaint acknowledgement. Patients are also advised they can request the

survey in other formats and languages should they require.

During 2020/21 there were a total of eleven completed surveys. Complainants who

completed the survey predominantly came under NHS Brighton and Hove CCG, had a

mental health disability, were female, and of white or Asian origin.

Notably all those who completed the survey were under 45 years of age. The Complaints

team is therefore implementing routinely attaching an electronic copy of the survey to

emails and letters to encourage a more widespread response.

One theme that arose in the course of this monitoring related to access to fertility

treatment for transgender and gay couples, particularly in relation to donor genetic

materials. The CCGs will be undertaking an Equality and Health Inequalities Impact

Assessment following the review of the policy; there are also plans for public engagement

events relating to this particular theme.

The prescribing of Liothyronine and the inequalities across the Sussex area was also a

theme that was identified 2020/21. In West Sussex a review will be urgently progressed by

means of virtual decision making. The CCG is hoping to have a formulary status and

shared care guidelines approved, in line with the Regional Medicines Optimisation

Committees’ (RMOC) recommendations.

11.0 Parliamentary and Health Service Ombudsman (PHSO) and Local

Government and Social Care Ombudsman (LGO)

During 2020/21 there have been no cases investigated by the PHSO which is considered

a reflection on the quality of the responses provided.

During 2020/21 the LGO and PHSO did however request information related to an

historical case that had previously been managed by SCW CSU on behalf of NHS

Hastings and Rother CCG and which was partially upheld. This related to Continuing

Healthcare. The PHSO made the following recommendations:

Within one month of the date of the final decision the CCG should write to the

complainant and acknowledge the failings identified

Further, the CCG should acknowledge the impact this had on the complainant and

apologise for the avoidable stress and physical discomfort experienced

Within three months of the date of the final decision the CCG should pay £1,000, to

act as a tangible acknowledgement of the impact

Within three months of the date of the final decision the CCG should review this

case and relevant policies and procedures on Personal Health Budgets

14

The CCG should ensure the relevant guidance is appropriately reflected,

understood and embedded in its own practice

The above recommendations were fully actioned, and further learning taken forward.

Information has also been requested during 2020/21 for a further case that was also

previously managed by the CSU which related to NHS Eastbourne, Hailsham and Seaford

CCG. This case relates to the Individual Funding Request processes and has just been

allocated a case officer. All information has been provided to the PHSO. The team awaits

confirmation as to whether the PHSO will investigate.

The Complaints team followed up with the PHSO regarding the outcomes of four

outstanding complaint cases managed by the former NHS Coastal West Sussex CCG

related to CHC. The PHSO has confirmed that each of these historical cases have now

been closed without further investigation.

The Complaints team has noticed an increase in investigations being undertaken by the

LGO. These are predominantly related to section 117 funding and commonly where no

complaint has previously been managed by the CCG. The LGO investigations are being

managed by the relevant Executive Managing Director to co-ordinate a response from the

Commissioning teams.

12.0 Horizon scanning: 2021/22

As with other CCG teams, the Complaints team is expecting a period of significant change

and various challenges going forward into 2021/22 with the expected publication of the

white paper in June 2021. The team expects to see potential changes in the way

complaints are managed in relation to GP, Opticians, Pharmacists and Dentists, together

with potentially some specialised commissioned services.

During 2020 the PHSO launched a public consultation on the Complaints Standards

Framework. In April 2021 the PHSO published the next steps for how the new framework

will be embedded. The Complaints team participates regularly in the NHS Complaints

Management Forum, where the PHSO were present in February 2021 to discuss the new

framework. The PHSO sought volunteers to review and provide feedback on the draft

framework together with those who wished to participate in the pilot scheme.

The CCGs’ Complaints team volunteered to be a part of the pilot and was subsequently

delighted to be informed by the PHSO that they had been chosen as one of twelve

participants out of more than 60 who had volunteered. The PHSO is currently tailoring a

programme for the CCGs to follow and we anticipate this will commence in September

2021 and run for one year. This is an extremely valuable opportunity to help shape the

future of the management of complaints nationally. To support this the Complaints team

will be running a survey for two weeks collating information from CCG staff, local provider

organisations, advocacy services, Healthwatch and lay people to assist the PHSO in

developing the pilot programme for the CCGs.

The Complaints team is further exploring the development of the quality of complaints

responses by undertaking an audit of responses to be completed during 2021 by the Lay

15

Members for Patient and Public Engagement. This audit would involve sending a

selection of five random complaints (anonymised) to the Lay Members for PPE, including

the incoming complaint letter, the acknowledgement letter, and the final response

letter. The Lay Members for PPE would then have the opportunity to review and give

feedback on areas for learning or improvement that the Complaints team can then

implement.

The imminent publication of the Clinical Harm Review, completed by NHS West Sussex

CCG, has already generated some complaints activity with more expected. Where

required, the CCG will work with NHS Resolution to assist those patients affected and

make the process as seamless as possible.

There continues to be a significant number of enquiries and concerns regarding the Covid-

19 vaccination programme, and whilst the Communications team is currently managing

the enquiries, they have recently commenced recording these on the Complaints team’s

database, with any MP enquiries managed as per the agreed policy by the CEO’s office.

The use of the complaints database will allow triangulation of the enquiries that are

received by the organisation from the public. Again, members of the public who wish to

escalate their enquiry to being a formal complaint are informed of the process and these

are managed, monitored and reported on by the Complaints team.

It is expected that there may be a significant increase in enquiries and complaints relating

to delayed procedures, with some already received in relation to the restoration and

recovery programme. The Complaints team continues to work closely with the

Commissioning and Communications teams to ensure responses are provided for general

enquiries and concerns to address these enquiries.

Finally, the CCGs’ Complaints policy was reviewed in February and March 2021. The

current Complaints policy follows the requirements of the NHS (Complaints) Regulations

2009, the PHSO Principles of Good Complaint Handling (2009) and the NHSE / I

Complaints Handling for CCGs (2013). The revised policy was presented to the LMTs on 1

and 2 June 2021, and is due to be presented to the Joint Quality Committee for ratification

on 15 June 2021.

16

Appendix A

Summary of quarter four activity

During quarter four the Complaints team received 280 contacts. Of these 89 were formal

complaints and 124 concerns and enquiries. There was notable increased activity

regarding GP concerns and the vaccination programme. The former was attributed to the

ongoing situation of the majority of appointments being conducted through the engage and

consult programme. A consistent theme regarding these GP concerns was in terms of

getting through to GP surgeries and overall telephone line issues. Enquirers were

encouraged to discuss with the relevant practice managers or consent was sought to

forward the feedback to the practice on their behalf.

There were also a total of 15 compliments received in quarter four. These included:

A care co-ordinator advising:

CHC provided brilliant support through lockdown.

Feedback for the Planned Care team, Complaints team and the provider service

First of all let me give my best wishes to you and your team for all the help they have given

me.

I am now delighted to report that the audiology team have pulled out all the stops in an

effort to get my hearing aids working correctly. I have had a fortnightly appointment and

am pleased to say that there has been great success. My hearing aids have never been

so good. I should particularly like to mention H at the H branch for his care and attention. I

have another appointment in two weeks’ time for some fine tuning.

Many thanks to all.

Feedback regarding a complex multi-provider complaint that necessitated going

back to the providers three times to ensure a thorough response.

Thank you for your support over the past year, I really appreciate you keeping me up to

date with the progress of our complaint.

17

Appendix B: Lessons Learnt Quarter 4

Whilst the CCGs would expect the majority of learning to be informed via complaints, the CCGs do not underestimate the value of PALS and

corporate correspondence cases that have also demonstrated actions and learning. An example has been included in the selection below.

The table below shows some of those lessons learned during Quarter four:

Table 8 – Lessons Learnt Quarter 4

Complaint summary Outcome Learning

Outcome of CHC assessment

addressed to deceased

relative. The CHC team was

informed following receipt of

the complaint but then

repeated it.

Upheld. The family experienced a delay between

the date of the CHC assessment and the date

the decision letter was sent and exceeded the

standard of 28 days as directed by the National

Framework for NHS Continuing Healthcare and

NHS-funded Nursing Care. The delays were

partly due to the current workload the CHC team

is experiencing due to the Covid-19 pandemic.

The CHC team was also required to wait for

WSCC to inform them that all of their

assessments were completed before the

temporary Covid-19 funding could be

discontinued. This regrettably also contributed to

the delays.

The CHC team's usual process with regards to a

family's bereavement is to pause all

correspondence for a period of four weeks as a

mark of respect. The team was unaware of the

recent loss and apologises for any distress

In cases where the CHC team does not hold all of the details

for the patient's representatives or families, nor have copies

of all the documentation in relation to consent, they should

not address the letters to anyone else except the patient. We

recognise however that the CHC team had previously been

communicating with the family without obtaining evidence

that this was in place.

Typing and grammatical errors in the DST, in particular the

misspelling of the patient's name. We recognise that

receiving such a document in relation to a loved one could

cause distress and apologised for this. We have ensured the

impact this had has been fed back to the senior members of

the CHC team so that they can ensure their teams are

mindful when completing such important documents of how

such errors can make families feel.

Having received a copy of the DST the nurse assessor

clarifies the relative was not present but was informed. We

recognise that the attempts to contact the family should have

18

caused by the family receiving this letter at such

a sensitive time. They also apologised that the

letter was addressed to the late relative.

been written more explicitly on the DST to ensure that this

made clear that the relative would have wished to participate

in the meeting had they received sufficient notice.

Prescribing of Liothyronine in

West Sussex

Upheld. Inequalities with East Sussex Liothyronine review will be urgently progressed by means of

virtual decision making. The CCG is hoping to have a

formulary status and shared care guidelines approved, in

line with RMOC recommendations, before the end of March

2021.

Attitude of CHC Nurse during

assessment.

Upheld. Sincere apology made to family as to

how they were made to feel.

CHC Nurse had interview with line manager during

complaint investigation and CHC promised final letter would

go to line manager to share with CHC Nurse in one to one

and discuss perception of behaviour as personal learning

opportunity.

Patient trying to contact

primary care service- left

holding for considerable time

with high charges.

Upheld. There has been an electrical fault but

staff not available 24 hours so delays in

communicating and updating sites.

Offer to reimburse cost of call on production of

bill.

The provider have made changes to their work practice to

ensure there is a member of their telephone diversion team

on-call to initiate any call diverts that may be required during

weekends and other out of hours. This will also apply to any

necessary website updates. These new measures will help

minimise any disruption to the service in the event of

electrical power failure affecting the telephone lines again.

Attitude of staff attending

home visit and refusal to

provide a receipt of the

removal of equipment.

Partially upheld. Flexibility should have been applied with regards to the receipt.

CCG noted that different generations of patients may prefer a paper receipt on returning equipment. This will be taken into consideration going forward when agreeing contracts with service providers.

Covid-19 Outbreak Testing in

sheltered housing

Partially Upheld. Understanding seemed to be more of a care home setting than sheltered housing so staff support would not have been the same.

As a result of the feedback it has been reiterated to the COVID-19 Booking Team the need to be clear and transparent with sheltered housing accommodation and other similar settings when initiating the Outbreak Testing process. This includes detailing the requirements of the process, what information they should receive from the

19

CCG, and an instruction to contact the CCG immediately should the information not be received. I have also instructed the COVID-19 Booking Team to ensure sheltered housing accommodation and other similar settings have full confidence in their capability and ability in conducting tests themselves before they proceed. Where they are less so and assistance is required, this is escalated quickly to ensure the appropriate support is provided and patient safety maintained.

Delays in surgery Partially upheld. Patient not previously been made aware of the CCG's criteria for hip surgery at named provider. In respect of patient BMI threshold requirements, all patients who undergo a hip replacement with a BMI of 35 or more are required to attend a minimum of 6 months conservative weight loss through the community tier three weight management service. This criteria is in place to ensure the best possible outcome for all patients who undergo hip replacement surgery. The CCG recognises this is a difficult and worrying time for patients waiting for planned care surgery. All patients within Sussex are being treated in priority and then chronological order and patients will not have lost their place on the waiting list as a result of being transferred to another hospital. However patients will only be contacted as soon as acute trusts have capacity.

Our teams are working collectively with the local hospital trust to help ensure patients' surgeries are carried out as soon as possible. We have also ensured learning as a result of this case and our Clinical Lead for Planned Care has therefore reviewed the CCG's referral process. Whilst our guidance does include a shared decision-making process that advises patients to lose weight if they fall into the overweight category, we will re-communicate this to referrers to ensure our process is strengthened.

PALS case re progression of

referral

Upheld- Regrettably this was a case of administrative error. The team received the referral which was correctly addressed to the

The team leader has followed up with any necessary re-training of their team to ensure they are correctly reading the

20

consultant at the appropriate hospital. After looking into this referral on their system it appears a selection of hospitals had been selected for the patient to choose within 10 days. This has since been rectified and the team has ensured they have booked an appointment for the named consultant.

referral letters received and processing them to the hospitals specified. They also sent their apologies, together with the CCG’s own, for any inconvenience caused in the interim.

Corporate correspondence

case from local GP raising

concerns about eating

disorder service.

Joint response sent from CCG and SPFT. We recognise that the current Eating Disorder service does not fully meet the needs of the Sussex-wide population that it serves and the associated pressures this places on other parts of the health system, including general practice. Confirmed that the challenges with the current service and the adverse impact on service user experience were recently discussed at the Sussex Health and Care Partnership Integrated Care System (ICS), Mental Health Collaborative Clinical Care and Strategy group meeting held on 19 January 2021. The outcome of this discussion led to an agreement to rapidly establish a new work stream to take forward the actions that were agreed. The new work stream will be established to both identify short term actions to improve the current access and service offer plus work together to create a new more joined up responsive service for people with eating disorders. The group will review the current Eating Disorder Service, look at currently what works well, highlight areas of best practice, identify service gaps and variation, together with the challenges and associated clinical risks in order to develop a revised Eating Disorder tiered

This plan was for the Sussex-wide review of Eating Disorder Services to commence in February 2021 and we anticipate it taking 4 months to conclude its recommendations, which will be presented to the Sussex Health and Care Partnership Integrated Care System (ICS), Mental Health Collaborative Clinical Care and Strategy group. It will also be responsible for suggesting shorter term solutions to improve the interface between Primary Care and SPFT team until the recommendations can be implemented. This review process provides us the opportunity to take advantage of the new money available via the mental health transformation programme as well as the mental health investment standard funds. It also ensures feedback such as the GP and that of other primary care colleagues can be heard by a wide audience and used to shape the future recommendations. GP invited to contact the CCG if they have the time to contribute to the review of the Eating Disorder Service. This was accepted. CCG will ensure that we provide progress updates to GP and their primary care colleagues via the existing primary care communications channels and locality meetings.

21

service model and pathway. The stakeholder review group will comprise of representatives from SPFT both clinical and managerial, primary care, the Local Medical Committee (LMC), CCG clinical and commissioning leads, as well as service user / carer representatives.

22

Appendix C: Complaint themes 2020/21

Complaint type and numbers Themes

GP practice concerns Lack of duty of care / level of care / co-ordination of care/delays

23

73 Behaviour / Attitude of staff 15

Communication 7

Prescribing 6

Appointment issues 5

DNAR during Covid-19 3

Accuracy of medical records 3

Referral issues 2

GP merger / closure 2

Patient choice 2

Deregistration 2

GP visits Covid-19 1

Shielding priority - Covid-19 1

Premium ‘phone line charges 1

Continuing Healthcare (CHC) Dissatisfied with outcome decision of assessment 15

51 Communication issues with CHC staff including perceived attitude / behaviour

14

Assessments not taking place / lack of progress 7

Dissatisfied with retrospective process and delays 5

Dissatisfied with CHC package of care / care home 4

Discharge planning 3

Lack of PPE in CHC funded care home 1

Delays in CHC FastTrack funding 1

Personal health budgets 1

Planned Care Delays in surgery / appointment delays 4

12 Delays in community audiology 2

Community Oxygen policy 1

Access to orthotics 1

Lack of Parkinson’s nurses 1

Patient not being told things 1

Referral system causing delays 1

Decommissioning of specialist dementia nurses 1

Sussex Partnership NHS Foundation Trust (SPFT) /

Quality / Co-ordination of care 18

Mental Health / Children’s and Adolescents’ Mental Health

Concerns regarding mental health provision / funding

7

Services (CAMHS) 35 Wait for appointments (CAMHS) 3

Clinical care CAMHS 3

Eating disorder service 2

Section 117 funding 2

23

Sussex Community NHS Foundation Trust (SCFT) /

Delays to appointments 6

Community care 18 Communication 4

Duty of care of health visitors / nurses 3

Clinical care 2

Co-ordination of care 1

Attitude of clinical staff 1

Delay of equipment 1

Surrey and Sussex Healthcare Co-ordination of care 3

NHS Trust (SASH) Discharge arrangements 2

11 Delays / errors with test results 2

Section 117 funding 1

Delayed diagnosis 1

IG Breach 1

Attitude / behaviour of staff 1

East Sussex Healthcare NHS Trust (ESHT)

Wrong / delayed diagnosis 1

6 Medication changes 1

Attitude / behaviour of staff 1

Overseas patient charge 1

Discharge planning 1

Referral system 1

Western Sussex Hospitals NHS Foundation Trust (WSHFT)

Wait for surgery 13

27 Clinical care 10

Duty of care of maternity services 2

Accuracy of medical records 1

Delay in diagnosis 1

Brighton and Sussex University Hospitals NHS Trust (BSUH)

Delays / cancellation of surgery / appointments 6

14 Co-ordination of care / quality of care 3

Discharge planning 2

Waiting times cancer services 2

Staff attitude / behaviour 1

Clinical Effectiveness In vitro fertilisation (IVF) policy 5

5

Medicines Optimisation Prescribing decisions 12

16 POD 4

MSK Services Access / quality of care 3

South East Coast Ambulance Service NHS Foundation Trust (SECAmb)

Attitude / behaviour of paramedic 2

4 Communication with call handler 1

Patient choice 1

24

CCG commissioning decisions Bariatric surgery criteria 1

7 Varicose veins criteria 1

Rhizotome injections 1

Electric wheelchair criteria 1

Access to physiotherapy for specialist condition 1

Cataract policy 1

Lack of community wound care 1

Local authority Patients discharged to care homes with Covid-19 2

8 Quality of care in care home 3

Duty of care / safeguarding in care home 1

Co-ordination of care 1

Record keeping in nursing home 1

Montefiore 2 Communication 2

NHSE 2 GIC clinic delays 2

Pharmacy 2 Prescribing issues 2

Public Health England 1

School nurse not making referral 1

Dental Access to dentist 1

2 Delay in referral to specialist dentistry 1

CCG staff 1 Attitude / behaviour / Communication issue 1

Courier delivering Covid-19 testing kits

No PPE 1

Vaccine Priority 2

7 Layout of vaccine centre 1

Attitude of staff at vaccine centre 2

Records updated incorrectly 2

LCS fertility service 1 Delays 1

LCS ear irrigation 2 Access to service 2

Covid-19 testing in sheltered housing 1

Communication 1

NHS111 5 Delays / communication 5

Best Care Diagnostics Ltd 2 Quality / delay in repeat scan 2

Queen Victoria Hospital (QVH) 1 Misdiagnosis 1

Integrated Care 24 1 Misdiagnosis 1

Sussex Dermatology Service 1 Communication 1